202180284
ADAMS, YOLANDA vs. KPH – CONSOLIDATION INC (DBA HCA HOUSTON HEALTHCARE KINGWOOD)
(Court 270, JUDGE DEDRA DAVIS)
Originally Published: DEC 9, 2021 | Republished:Feb 18, 2023
DEFENDANT KPH-CONSOLIDATION, INC. D/B/A HCA HOUSTON HEALTHCARE KINGWOOD’S FIRST SUPPLEMENTAL RESPONSE TO PLAINTIFF’S REQUEST FOR DISCLOSURES AND DESIGNATION OF EXPERT WITNESSES
A. RETAINED EXPERTS
Prasanth Boyareddigari, MD
(1) the expert’s name, address, and telephone number;
RESPONSE: Prasanth Boyareddigari, MD
3707 Durness Way
Houston, Texas 77025
T: (713) 397-6234
(2) the subject matter on which the expert will testify;
RESPONSE: Emergency medicine and provision of health care
(3) the general substance of the expert’s mental impressions and opinions held by the expert and the basis for them, or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control; and
RESPONSE: Dr. Boyareddigari is Board Certified in Emergency Medicine. Further details of Dr. Boyareddigari’s credentials, professional background, qualifications, and experience, which also serve as a basis of his opinions herein, are set forth in his curriculum vitae, which is fully incorporated herein for all purposes.
He will testify regarding the applicable standard of care for HCA Houston Healthcare Kingwood, including its employees, agents, and representatives, with respect to the care and treatment of patients, such as Ms. Adams. Dr. Boyareddigari is expected to offer opinions on all elements of this case including but not limited to standard of care, allegations of breach in the standard of care, causation, and alleged damages.
Dr. Boyareddigari will offer testimony in rebuttal to Plaintiff’s designated experts’ opinions of standard of care, negligence, foreseeability, proximate cause, and damages.
(Also see the oral deposition of Dr. Boyareddigari which will or may be taken in this matter.)
Since Plaintiff’s designated liability experts have not yet been deposed, Defendant hereby reserves its right pursuant to the Texas Rules of Procedure, including but not limited to Rule 195 and the Court’s Docket Control Order, to supplement and/or amend this disclosure with respect to Dr. Boyareddigari’s opinions and/or rebuttal opinions until after Plaintiff’s designated experts have been deposed.
The basis for Dr. Boyareddigari’s opinions is not only his knowledge, training, skill, and experience, but also his review of Ms. Adams’ medical records and scientific peer reviewed literature and all of the documents and materials he has reviewed or may review in this case.
Dr. Boyareddigari will testify about the applicable standards of care for the diagnosis, care, and treatment of patients like Ms. Adams.
He will testify that Dr. Coelho and the HCA Houston Healthcare Kingwood nurses’ care and treatment of Ms. Adams was appropriate in all ways.
In particular, he will testify about appropriate treatments for patients following a fall on the ice and appropriate nursing and medical management of a patient following such a fall.
He will also discuss appropriate methods for working up a patient’s complaints of weakness and numbness in a patient like Ms. Adams, including imaging and appropriateness of discharge.
He will testify that Ms. Adams’ complaints of weakness and numbness were appropriately addressed by nursing personnel and that she was appropriately worked up for the fall.
Dr. Boyareddigari will testify that the nurses took the proper steps in implementing the physicians’ orders, properly communicated their findings to the physicians, and properly assessed the patient.
Dr. Boyareddigari will testify that the nurses made the physician team aware of Ms. Adams’ complaint of generalized weakness at the time of discharge.
Dr. Boyareddigari will further testify that it was appropriate to discharge Ms. Adams on the morning of February 17, 2021 and that she was discharged appropriately by the hospital’s nurses.
More specifically, Dr. Boyareddigari will testify that HCA Houston Healthcare Kingwood, as well as its employees, agents and representatives, including Dr. Rainna Coelho, met the standard of care and that nothing they did or failed to do was a proximate cause of Ms. Adams’ alleged injuries.
Dr. Boyareddigari will also testify about his training, background, and qualifications to render opinions in this case, as well as the materials he reviewed and relied upon in coming to his opinions.
Dr. Boyareddigari may rely on medical literature, including articles referenced by both plaintiff and defense experts.
Additionally, Dr. Boyareddigari may testify regarding the mental impressions and opinions of Plaintiff’s experts and the health care providers of Ms. Adams.
Defendant reserves the right to offer testimony from Dr. Boyareddigari which is consistent with the scope of this designation even if not set out word-for- word herein.
Dr. Boyareddigari may also offer additional opinions based on his review of the medical records in this case. Please refer to Dr. Boyareddigari’s deposition, if taken.
(4) if the expert is retained by, employed by, or otherwise subject to your control:
(a) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and
RESPONSE: Dr. Boyareddigari has reviewed the following documents:
· Medical Records of Yolanda Adams
o HCA Houston Healthcare Kingwood Medical Records, ADAMS0001-0090
o Memorial Hermann The Woodlands Medical Records, ADAMS0803-2762
· Plaintiff Expert Reports
o Susan Smith, RN, DNP
o Stanley Lee, MD
· Depositions
o Deposition of Yolanda Adams
o Deposition of Oliver Blome
o Deposition of Christian Sonnier, MD
All documents have either been produced or are available for inspection and copying.
(b) the expert’s current resume and bibliography.
RESPONSE: See Dr. Boyareddigari’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000959-000961.
(c) the expert’s qualifications, including all publications authored in last ten (10) years
RESPONSE: See Dr. Boyareddigari’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000959-000961.
(d) except when the expert is the responding party’s attorney and is testifying to attorney’s fees, a list of all cases in which the expert, during the previous four (4) years has testified at trial or deposition
RESPONSE: Defendant will supplement.
(e) a statement of compensation to be paid for expert’s study and testimony in the case.
RESPONSE: Defendant will supplement at the time of Dr. Boyareddigari’s deposition.
Mohammad Etminan, MD
(1) the expert’s name, address, and telephone number;
RESPONSE: Mohammad Etminan, MD
23530 Kingsland Blvd. #300
Katy, Texas 77494
T: (832) 277-4501
(2) the subject matter on which the expert will testify;
RESPONSE: Orthopedic and spine surgery and provision of health care
(3) the general substance of the expert’s mental impressions and opinions held by the expert and the basis for them, or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control;
and
RESPONSE: Dr. Etminan is Board Certified in orthopedic surgery and specializes in spine surgery. Further details of Dr. Etminan’s credentials, professional background, qualifications, and experience, which also serve as a basis of his opinions herein, are set forth in his curriculum vitae, which is fully incorporated herein for all purposes.
He will testify regarding the cause of Ms. Adams’ alleged injuries.
Dr. Etminan will testify specifically that no alleged act or omission by Defendant proximately caused the injuries and damages in this case.
Dr. Etminan will offer testimony in rebuttal to Plaintiff’s designated experts’ opinions of damages.
(Also see the oral deposition of Dr. Etminan which will or may be taken in this matter.)
Since Plaintiff’s designated causation experts have not yet been deposed, Defendant hereby reserves its right pursuant to the Texas Rules of Procedure, including but not limited to Rule 195 and the Court’s Docket Control Order, to supplement and/or amend this disclosure with respect to Dr. Flavin’s opinions and/or rebuttal opinions until after Plaintiff’s designated experts have been deposed.
The basis for Dr. Etminan’s opinions is not only his knowledge, training, skill, and experience, but also include his review of Ms. Adams’ medical records and scientific peer reviewed literature and all of the documents and materials he has reviewed or may review in this case.
Dr. Etminan will testify that the timing of Ms. Adams’ decompression surgery did not affect her ultimate outcome based on her specific injury.
Dr. Etminan will testify that, in reasonable medical probability, one cannot say surgical decompression within 8-24 hours after Ms. Adams’ fall would have prevented her cord compression injury.
Dr. Etminan will further testify that the damage to Ms. Adams’ spinal cord occurred at the time of the initial impact from her fall.
Dr. Etminan will also testify that any complaints related to Ms. Adams’ lower body are as result of her underlying chronic lower lumbar issues and are unrelated to her cord compression.
Dr. Etminan will also testify about his training, background, and qualifications to render opinions in this case, as well as the materials he reviewed and relied upon in coming to his opinions.
Dr. Etminan may rely on medical literature, including articles referenced by both plaintiff and defense experts.
Additionally, Dr. Etminan may testify regarding the mental impressions and opinions of Plaintiff’s experts and the health care providers of Ms. Adams.
Defendant reserves the right to offer testimony from Dr. Etminan which is consistent with the scope of this designation even if not set out word-for-word herein.
Dr. Etminan may also offer additional opinions based on his review of the medical records in this case.
Please refer to Dr. Etminan’s deposition, if taken.
(4) if the expert is retained by, employed by, or otherwise subject to your control:
(a) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony;
and
RESPONSE: Dr. Etminan has reviewed the following documents:
· Medical Records of Yolanda Adams
o Atascosita EMS (Medical)
o Atascosita EMS (Billng)
o CVS Pharmacy (Pharmacy)
o Cypress Creek EMS (Medical)
o Cypress Creek EMS (Billing)
o Family Medicine Clinic & Women Health (Medical)
o HCA Houston Healthcare Kingwood (Medical)
o HCA Houston Healthcare Kingwood (Billing)
o HCA Houston Healthcare Kingwood (Radiology)
o HEB Pharmacy (Pharmacy)
o Kroger (Pharmacy)
o Medicaid Texas Health & Human Services (Explanation of Benefits)
o Memorial Hermann Northeast Hospital (Medical)
o Memorial Hermann Northeast Hospital (Billing)
o Memorial Hermann Outpatient Imaging The Woodlands (Medical)
o Memorial Hermann The Woodlands Hospital (Medical)
o Memorial Hermann The Woodlands Hospital (Billing)
o Memorial Hermann TIRR (Medical)
o Memorial Hermann TIRR (Billing)
o UnitedHealthcare (Explanation of Benefits)
o Walmart (Pharmacy)
· Plaintiff Expert Reports
o Srinivason Parthasarathy, MD – Catastrophic Life Care Plan,
ADAMS3434-3674
o Brittany Pearce, MA – Life Care Plan,
ADAMS3678-3784
o Kendall Jones, MD
o Stanley Lee, MD
o Kenneth Totz, DO
· Depositions
o Deposition of Yolanda Adams
o Deposition of Oliver Blome
o Deposition of Christian Sonnier, MD
All documents have either been produced or are available for inspection and copying.
(b) the expert’s current resume and bibliography.
RESPONSE: See Dr. Etminan’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000962-000967.
(c) the expert’s qualifications, including all publications authored in last ten (10) years
RESPONSE: See Dr. Etminan’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000962-000967.
(d) except when the expert is the responding party’s attorney and is testifying to attorney’s fees, a list of all cases in which the expert, during the previous four (4) years has testified at trial or deposition
RESPONSE: Defendant will supplement.
(e) a statement of compensation to be paid for expert’s study and testimony in the case.
RESPONSE: Defendant will supplement at the time of Dr. Etminan’s deposition.
Kara Flavin, MD
(1) the expert’s name, address, and telephone number;
RESPONSE: Kara Flavin, MD
274 Redwood Shores Parkway, #534 Redwood City, California 94065
T: (650) 793-7657
(2) the subject matter on which the expert will testify;
RESPONSE: Rehabilitation medicine and provision of health care
(3) the general substance of the expert’s mental impressions and opinions held by the expert and the basis for them, or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control; and
RESPONSE: Dr. Flavin is Board Certified in Physical Medicine and Rehabilitation, with a special interest in spinal cord injury, traumatic brain injury, stroke recovery, and spasticity management.
Further details of Dr. Flavin’s credentials, professional background, qualifications, and experience, which also serve as a basis of her opinions herein, are set forth in her curriculum vitae, which is fully incorporated herein for all purposes.
She will testify regarding the care and treatment of Ms. Adams since the alleged incident in February 2021.
Dr. Flavin will testify regarding reasonable future medical care, rehabilitation, medication, equipment, transportation, home services, facility services, and other needs that may be necessary for patients experiencing the types of injuries presented by Ms. Adams.
Dr. Flavin will offer opinions regarding life expectancy and the medical and epidemiological literature used to calculate Ms. Adams’ life expectancy.
Dr. Flavin will offer testimony in rebuttal to Plaintiff’s designated experts’ opinions of damages.
(Also see the oral deposition of Dr. Flavin which will or may be taken in this matter.)
Since Plaintiff’s designated damages experts have not yet been deposed, Defendant hereby reserves its right pursuant to the Texas Rules of Procedure, including but not limited to Rule 195 and the Court’s Docket Control Order, to supplement and/or amend this disclosure with respect to Dr. Flavin’s opinions and/or rebuttal opinions until after Plaintiff’s designated experts have been deposed. Defendant reserves the right for Dr. Flavin to perform an independent medical examination of Ms. Adams.
Further, Defendant reserves the right to supplement and amend this designation until after Dr. Flavin has an opportunity to examine Ms. Adams.
The basis for Dr. Flavin’s opinions is not only her knowledge, training, skill, and experience, but also include her review of Ms. Adams’ medical records and scientific peer reviewed literature and all of the documents and materials she has reviewed or may review in this case.
Dr. Flavin will testify about Ms. Adams’ reasonable future medical care, rehabilitation, medication, equipment, transportation, home services, facility services, and other needs.
Specifically, Dr. Flavin will testify that Ms. Adams is an incomplete quadriplegic and has regained a significant amount of function in mobility and completing her ADLs since the incident in February 2021.
Dr. Flavin will further testify that Ms. Adams is unlikely to develop pressure injuries.
Dr. Flavin will also testify about her training, background, and qualifications to render opinions in this case, as well as the materials she reviewed and relied upon in coming to her opinions.
Dr. Flavin may rely on medical literature, including articles referenced by both plaintiff and defense experts.
Additionally, Dr. Flavin may testify regarding the mental impressions and opinions of Plaintiff’s experts and the health care providers of Ms. Adams.
Defendant reserves the right to offer testimony from Dr. Flavin which is consistent with the scope of this designation even if not set out word-for-word herein.
Dr. Flavin may also offer additional opinions based on her review of the medical records in this case.
Please refer to Dr. Flavin’s deposition, if taken.
(4) if the expert is retained by, employed by, or otherwise subject to your control:
(a) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and
RESPONSE: Dr. Flavin has reviewed the following documents:
· Medical Records of Yolanda Adams
o Memorial Hermann NE Medical Records, ADAMS0091-0802
o Memorial Hermann The Woodlands Medical Records, ADAMS0803-2762
o TIRR Memorial Hermann Hospital Medical Records (Received by Affidavit)
o HEB Pharmacy Records (Received by DWQ)
o Medical Records from Family Medicine and Women’s Health (Received from Lexitas 10.17.22)
o Performance Medicine at the Woodlands Hospital (Received by DWQ)
· Plaintiff Expert Reports
o Srinivason Parthasarathy, MD – Catastrophic Life Care Plan, ADAMS3434-3674
o Brittany Pearce, MA – Life Care Plan, ADAMS3678-3784
· Depositions
o Deposition of Yolanda Adams
o Deposition of Oliver Blome
o Deposition of Christian Sonnier, MD
All documents have either been produced or are available for inspection and copying.
(b) the expert’s current resume and bibliography.
RESPONSE: See Dr. Flavin’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000969-000971.
(c) the expert’s qualifications, including all publications authored in last ten (10) years
RESPONSE: See Dr. Flavin’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000969-000971.
(d) except when the expert is the responding party’s attorney and is testifying to attorney’s fees, a list of all cases in which the expert, during the previous four (4) years has testified at trial or deposition
RESPONSE: See attached bearing bates labels ADAMS KINGWOOD 000968.
(e) a statement of compensation to be paid for expert’s study and testimony in the case.
RESPONSE: Defendant will supplement at the time of Dr. Flavin’s deposition.
Ginny Stegent, RN, CRRN, CDMS, CLCP
(1) the expert’s name, address, and telephone number;
RESPONSE:
Ginny Stegent, RN, CRRN, CDMS, CLCP
506 Heights Blvd.
Houston, Texas 77007
T: (713) 726-1221
(2) the subject matter on which the expert will testify;
RESPONSE: Life care planning
(3) the general substance of the expert’s mental impressions and opinions held by the expert and the basis for them, or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control; and
RESPONSE: Ms. Stegent is a certified life care planner, certified rehabilitation registered nurse, registered nurse, and certified disability management specialist.
Further details of Ms. Stegent’s credentials, professional background, qualifications, and experience, which also serve as a basis of her opinions herein, are set forth in her curriculum vitae, which is fully incorporated herein for all purposes.
She will testify regarding Ms. Adams’ future medical and custodial needs.
The subject matter of Ms. Stegent’s testimony will include Ms. Adams’ current health condition, the progression of that condition, and her likely prognosis as well as the reasonable cost(s) associates with Ms. Adams’ further medical and custodial needs.
She will offer testimony in rebuttal to Plaintiff’s designated experts’ in the area of future recommended care and the costs associated with future care needs including attendant care needed, if any.
Ms. Stegent will offer testimony in rebuttal to Plaintiff’s designated experts’ opinions of damages.
(Also see the oral deposition of Ms. Stegent which will or may be taken in this matter.)
Since Plaintiff’s designated damages experts have not yet been deposed, Defendants hereby reserve their right pursuant to the Texas Rules of Procedure, including but not limited to Rule 195 and the Court’s Docket Control Order, to supplement and/or amend this disclosure with respect to Ms. Stegent’s opinions and/or rebuttal opinions until after Plaintiff’s designated experts have been deposed.
The basis for Ms. Stegent’s opinions is not only her knowledge, training, skill, and experience, but also include her review of Ms. Adams’ medical records and scientific peer reviewed literature and all of the documents and materials she has reviewed or may review in this case.
Ms. Stegent will testify about Ms. Adams’ reasonable future medical care, rehabilitation, medication, equipment, transportation, home services, facility services, and other needs.
Ms. Stegent will also testify about her training, background, and qualifications to render opinions in this case, as well as the materials she reviewed and relied upon in coming to her opinions.
Ms. Stegent may rely on medical literature, including articles referenced by both plaintiff and defense experts.
Additionally, Ms. Stegent may testify regarding the mental impressions and opinions of Plaintiff’s experts and the health care providers of Ms. Adams.
Defendant reserves the right to offer testimony from Ms. Stegent which is consistent with the scope of this designation even if not set out word-for-word herein.
Ms. Stegent may also offer additional opinions based on her review of the medical records in this case.
Please refer to Ms. Stegent’s deposition, if taken.
(4) if the expert is retained by, employed by, or otherwise subject to your control:
(a) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony;
and
RESPONSE: Ms. Stegent has reviewed the following documents:
· Medical Records of Yolanda Adams
o Memorial Hermann NE Medical Records, ADAMS0091-0802
o Memorial Hermann The Woodlands Medical Records, ADAMS0803-2762
o TIRR Memorial Hermann Hospital Medical Records (Received by Affidavit)
o HEB Pharmacy Records (Received by DWQ)
o Medical Records from Family Medicine and Women’s Health (Received from Lexitas 10.17.22)
o Performance Medicine at the Woodlands Hospital (Received by DWQ)
· Plaintiff Expert Reports
o Srinivason Parthasarathy, MD – Catastrophic Life Care Plan, ADAMS3434-3674
o Brittany Pearce, MA – Life Care Plan, ADAMS3678-3784
· Depositions
o Deposition of Yolanda Adams
o Deposition of Oliver Blome
o Deposition of Christian Sonnier, MD
All documents have either been produced or are available for inspection and copying.
(b) the expert’s current resume and bibliography.
RESPONSE: See Ms. Stegent’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000982-000986.
(c) the expert’s qualifications, including all publications authored in last ten (10) years
RESPONSE: See Ms. Stegent’s CV attached hereto bearing bates labels ADAMS KINGWOOD 000982-000986.
(d) except when the expert is the responding party’s attorney and is testifying to attorney’s fees, a list of all cases in which the expert, during the previous four (4) years has testified at trial or deposition
RESPONSE: See attached bearing bates labels ADAMS KINGWOOD 000978-000981.
(e) a statement of compensation to be paid for expert’s study and testimony in the case.
RESPONSE: Defendant will supplement at the time of Ms. Stegent’s deposition.
Helen Reynolds, MA, PhD
(1) the expert’s name, address, and telephone number;
RESPONSE: Helen Reynolds, MA, PhD
4131 N. Central Expwy., Suite 445
Dallas, Texas 75204
T: 214-219-8100
(2) the subject matter on which the expert will testify;
RESPONSE: Economic damages
(3) the general substance of the expert’s mental impressions and opinions held by the expert and the basis for them, or documents reflecting such information if the expert is not retained by, employed by, or otherwise subject to your control;
and
RESPONSE: Dr. Reynolds is an economist. Further details of Dr. Reynolds’ credentials, professional background, qualifications, and experience, which also serve as a basis of her opinions herein, are set forth in her curriculum vitae, which is fully incorporated herein for all purposes.
She will testify regarding the calculations made for any life care plan and/or economic damages proposed for Ms. Adams and/or any claim asserted for lost earing capacity, including the present value of same.
She will offer testimony in rebuttal to Plaintiff’s designated experts’ in the area of future recommended care and the costs associated with future care needs including attendant care needed, if any.
Dr. Reynolds will offer testimony in rebuttal to Plaintiff’s designated experts’ opinions of damages.
(Also see the oral deposition of Dr. Reynolds which will or may be taken in this matter.)
Since Plaintiff’s designated damages experts have not yet been deposed, Defendant hereby reserve its right pursuant to the Texas Rules of Procedure, including but not limited to Rule 195 and the Court’s Docket Control Order, to supplement and/or amend this disclosure with respect to Dr. Reynolds’ opinions and/or rebuttal opinions until after Plaintiff’s designated experts have been deposed.
The basis for Dr. Reynolds’ opinions is not only her knowledge, training, skill, and experience, but also include her review of Ms. Adams’ medical records and scientific peer reviewed literature and all of the documents and materials she has reviewed or may review in this case.
Dr. Reynolds will also testify about her training, background, and qualifications to render opinions in this case, as well as the materials she reviewed and relied upon in coming to her opinions.
Dr. Reynolds may rely on medical literature, including articles referenced by both plaintiff and defense experts.
Additionally, Dr. Reynolds may testify regarding the mental impressions and opinions of Plaintiff’s experts and the health care providers of Ms. Adams.
Defendant reserves the right to offer testimony from Dr. Reynolds which is consistent with the scope of this designation even if not set out word-for-word herein. Dr. Reynolds may also offer additional opinions based on her review of the medical records in this case. Please refer to Dr. Reynolds’ deposition, if taken.
(4) if the expert is retained by, employed by, or otherwise subject to your control:
(a) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony; and
RESPONSE: Dr. Reynolds has reviewed the following documents:
· Medical Records of Yolanda Adams
o Memorial Hermann NE Medical Records, ADAMS0091-0802
o Memorial Hermann The Woodlands Medical Records, ADAMS0803-2762
o TIRR Memorial Hermann Hospital Medical Records (Received by Affidavit)
o HEB Pharmacy Records (Received by DWQ)
o Medical Records from Family Medicine and Women’s Health (Received from Lexitas 10.17.22)
o Performance Medicine at the Woodlands Hospital (Received by DWQ)
· Plaintiff Expert Reports
o Srinivason Parthasarathy, MD – Catastrophic Life Care Plan, ADAMS3434-3674
o Brittany Pearce, MA – Life Care Plan, ADAMS3678-3784
o Gary Kronrad, PhD Report
· Depositions
o Deposition of Yolanda Adams
o Deposition of Oliver Blome
o Deposition of Christian Sonnier, MD
All documents have either been produced or are available for inspection and copying.
(b) the expert’s current resume and bibliography.
RESPONSE: See Dr. Reynolds’ CV attached hereto bearing bates labels ADAMS KINGWOOD 000977.
(c) the expert’s qualifications, including all publications authored in last ten (10) years
RESPONSE: See Dr. Reynolds’ CV attached hereto bearing bates labels ADAMS KINGWOOD 000977.
(d) except when the expert is the responding party’s attorney and is testifying to attorney’s fees, a list of all cases in which the expert, during the previous four (4) years has testified at trial or deposition
RESPONSE: See attached bearing bates labels ADAMS KINGWOOD 000972-000976.
(e) a statement of compensation to be paid for expert’s study and testimony in the case.
RESPONSE: Defendant will supplement at the time of Dr. Reynolds’ deposition.
B. PARTY EXPERTS
The following are parties to this litigation. In addition to factual testimony, they may be called to give testimony in the form of opinions within the scope of their expertise. Their opinions may be found in the medical and/or business records produced in discovery and/or their depositions, if taken, which Defendant incorporates herein by reference.
Employees, Agents, Representatives and Custodian of Records:
KPH-Consolidation, Inc. d/b/a HCA Houston Healthcare Kingwood
By and through its attorneys of record:
Nicole Andrews
Amanda Schramm
SERPE | ANDREWS, PLLC
America Tower
2929 Allen Parkway, Suite 1600
Houston, Texas 77019
(713) 452-4400
Defendant/Healthcare Provider Including, but not limited to:
Coelho, Raina, MD
Flores, Barney, Rad Tech
Leger, Alleigh, Rad Tech
McRae, Kenneth, Rad Tech
Morales, Heidi, RN
Murillo, Yesenia Andrade, Rad Tech
Shideler, Christine, RN
Sony, Riley, Tech
Syelate, Estanislao, Rad Tech
White, Justin, W., RN
Winton, Tiffany R., RT (R)
Employees, Agents, Representatives and Custodian of Records:
Eric Lopez, M.D.
By and through his attorneys of record:
Joel Sprott
Diana Navarro
Sprott, Newsom, Quattlebaum, & Messenger
2211 Norfolk, Suite 1150
Houston, Texas 77098
(713) 523-8338
Defendant/Healthcare Provider
Employees, Agents, Representatives and Custodian of Records:
Daniel Bonville, D.O.
By and through his attorneys of record:
Frank Doyle
Lina Al-Salim
MYERS DOYLE
7676 Woodway, Suite 350
Houston, Texas 77063
(713) 278-9215
Defendant/Healthcare Provider
C. HEALTHCARE PROVIDERS
The following are/were treating physicians, nurses, and other healthcare providers for Plaintiff Yolanda Adams.
They have not been formally retained as testifying experts by Defendant. They may be called on to give testimony in the form of opinions within their respective areas of expertise and treatment of Plaintiff.
Their testimony and opinions are based upon personal knowledge, training, education, and experience.
Their opinions and the basis for them may be found in the medical records and their depositions, if taken, which Defendant incorporates herein by reference.
Employees, Agents, Representatives and Custodian of Records:
Atascocita Fire Department
Nugent, Heidi, LM1-P
Stevens, Jessica, EMT-P 18425
Timber Forest Drive
Humble, TX 77346
(281) 852-2181
Emergency Medical Services/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Bathurst, Christopher, MD
12951 South Fwy
Houston, TX 77047
(254) 298-2682
Radiologist/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience. This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries. The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Cypress Creek EMS
7111 Five Forks
Spring, TX 77379
281-378-0800
Emergency Medical Services/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Encompass Health Rehab Hospital of The Woodlands
18550 I-45
Shenandoah, TX 77384
281-364-2000
Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Family Medicine Clinic & Women Health
9000 Forest Crossing Drive
Spring, TX 77381
(281) 681-0616
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
HEB Pharmacy
River Anex Compliance Bldg
646 South Flores
San Antonio, TX 78204
210-938-8000
Pharmacy/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries. The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Kroger Pharmacy
1014 Vine Street
Cincinnati, OH 45202
800-576-4377
Pharmacy/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Memorial Hermann Northeast Hospital
18951 West Memorial Drive Humble, TX 77338
(281) 540-7700
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Memorial Hermann
The Woodlands Medical Center
9250 Pinecroft Drive
Shenandoah, TX 77380
(713) 897-2300
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Praisoody, Sankaman, MD
12951 South Fwy
Houston, TX 77047
(713) 334-1837
Radiologist/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Reddy, Anjali Gaddam, C-FNP
9000 Forest Crossing Drive
Spring, TX 77381
(281) 681-0616
Nurse Practitioner/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Sonnier, Christian MD
23330 US-59
Kingwood, TX 77339
Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries. The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
St. Luke’s Health – The Woodlands Hospital
17200 St. Lukes Way
The Woodlands, TX 77384
(936) 266-2000
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
TIRR Memorial Hermann
1333 Moursund Street
Houston, TX 77030
(800) 447-3422
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
TIRR Memorial Hermann
The Woodlands Medical Center
9250 Pinecroft Drive
Shenandoah, TX 77380
(800) 447-3422
Healthcare Facility/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Walgreens
P.O. Box 4039
Mail Stop 735
Danville, TX 61834
217-709-2230
Pharmacy/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Wen, Xianfeng, MD
2627 Chestnut Ridge Rd., Suite 100
Kingwood, TX 77339
(281) 358-1950
Cardiologist/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries. The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Employees, Agents, Representatives and Custodian of Records:
Woo, Cynthia L., MD
1515 Holcombe Blvd. #97
Houston, TX 77030
(713) 563-2300
Radiologist/Healthcare Provider
May be called and provide testimony in the form of opinions within the respective areas of expertise regarding the treatment of Ms. Adams and the testimony and opinions are based upon assessments, personal knowledge, training, education, and experience.
This provider may address all aspects of care, Ms. Adams’ past medical history, including but not limited to medical causation for plaintiff’s alleged injuries.
The opinions of the provider, and the general basis for same, may be found in the medical records and their depositions, if taken, which Defendant incorporates by reference.
Further, Defendant incorporates by reference all persons identified by any party, former party, and/or settling party as a person having knowledge of relevant facts, and specifically reserves the right to call such person(s) to testify at the trial of this matter.
D. CO-DEFENDANTS’ EXPERTS
Defendant reserves the right to call any expert(s) designated by the Co-Defendants.
They may be called on to give testimony in the form of opinions within the scope of their expertise.
Such witnesses, if any, have not been formally retained as testifying experts by this Defendant.
By reserving the right to call such witnesses, if any, Defendant makes no assumed representation or affirmation regarding their qualifications or the validity of their opinions.
Such witnesses, if any, may be called to give testimony in the form of opinions within their respective areas of purported expertise.
Their opinions and the basis for them may be found in the medical and/or business records produced during discovery, their depositions, if taken, and their reports, if any, all of which is incorporated herein by reference for all points and purposes.
Defendant reserves the right to present any and all of their opinions as expressed in Co-Defendants’ Designations of Experts or in the respective designated witness’ reports for any and all purposes at the time of trial.
Theresa R. Harring, MD
1811 Woodcrest Dr.
Houston, TX 77018
T: (281) 900-7101
E. PLAINTIFF’S EXPERTS
Defendant reserves the right to call any and all retained witnesses designated by Plaintiff.
Such witnesses, if any, have not been formally retained as testifying experts by Defendant. By reserving the right to call such witnesses, if any,
Defendant makes no assumed representation or affirmation regarding their qualifications or the validity of their opinions.
Such witnesses, if any, may be called to give testimony in the form of opinions within their respective areas of purported expertise. Their opinions and the basis for them may be found in the medical and/or business records produced during discovery, their depositions, if taken, and their reports, if any, all of which is incorporated herein by reference for all points and purposes.
Defendant reserves the right to present any and all of their opinions as expressed in Plaintiff’s Designation of Experts or in the respective designated witness’ reports for any and all purposes at the time of trial.
Susan K. Smith, DNP, RN, CEN, CCRN, CNLCP, CWOCN
P.O. Box 161
4498 Meadow Wood Ln.
Warriors Mark, PA 16877
814-777-2928
Kenneth Totz, DO, FACEP
10830 Long Shadow Ln.
Houston, TX 77024
713-446-1202
Kendall Jones, MD
3304 Communications Pkwy., Suite 201
Plano, TX 75093
214-629-4450
Stanley S. Lee, MD
3010 Washtenaw Ave., Suite A107
Ann Arbor, MI 48104
734-707-7277
S. Roger Parthasarathy, MD
Physician Life Care Planning
12707 Silicon Dr., Suite 150
San Antonio, TX 78249
210-501-0995
Brittany Pearce,
MA Physician Life Care Planning
12707 Silicon Dr., Suite 150
San Antonio, TX 78249
210-501-0995
Gary Kronrad, Ph.D.
179 County Road 231
Nacogdoches, TX 75961
936-468-2473
F. CUSTODIANS
The Custodians of Records of the healthcare providers and other entities identified in Exhibit A may testify either live or by deposition to prove up business records as admissible per the Business Records Act and Rules 803 and 902 of the Texas Rules of Evidence.
They may further testify, where applicable, as to the amount of medical and/or other expenses paid or incurred by Plaintiff and those amounts for which Plaintiff is no longer liable.
G. RESERVATIONS
Defendant reserves the right to supplement this designation with additional expert witnesses within the time limits imposed by the Court or any alterations of same by subsequent Court order or agreement of the parties, or pursuant to the Texas Rules of Civil Procedure and/or the Texas Rules of Evidence.
Defendant reserves the right to withdraw the designation of any expert and to aver positively that any such previously designated expert will not be called as a witness at trial, and to re-designate same as a consulting expert who cannot be called by opposing counsel.
Defendant reserves the right to call undesignated rebuttal expert witnesses.
Defendant reserves the right to elicit any expert opinion or lay opinion testimony at the time of trial that would be of benefit to the jury to determine material issues of fact and that would not violate any existing Court order or the Texas Rules of Evidence.
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Amanda Johnson on behalf of Amanda Schramm Bar No. 24098392
ajohnson@serpeandrews.com Envelope ID: 70941687
Status as of 12/13/2022 7:44 AM CST
doctor
